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disallowance of the claimed travel, meals, and entertainment
expenses.
As discussed above, respondent conceded in full the
adjustments to petitioner's claimed rent or lease expenses and
utilities expenses. Respondent also conceded $870 of the
adjustment to petitioner's claimed car and truck expenses and
$284 of the adjustment to petitioner's claimed
depreciation/section 179 expense deduction. The remaining
adjustments in the notice of deficiency, to petitioner's claimed
car and truck expenses, depreciation/section 179 expense
deduction, and travel, meals, and entertainment expenses have
been sustained by the Court. Petitioner's evidence fell short of
what was required to allow the bulk of the claimed car and truck
expenses and depreciation/section 179 expense deduction, or any
of the claimed travel, meals, and entertainment expenses.
Furthermore, petitioner presented no evidence to show that he
used due care in claiming the disputed items on his 1997 return
that were subsequently adjusted in the notice of deficiency and
sustained by this Court in favor of respondent, nor did
petitioner present evidence to show that he had reasonable cause
to claim such items. Petitioner failed to maintain adequate
books and records to support the majority of the costs and
deductions at issue herein. Therefore, the Court finds that
petitioner negligently or intentionally disregarded rules or
regulations with regard to the adjustments in the notice of
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Last modified: May 25, 2011